Union of India v. Rajeev Bansal

469 ITR 46Supreme Court of India2024#72 most cited

What is Union of India v. Rajeev Bansal authority for?

The legal fiction created by the Ashish Agarwal judgment stops the limitation clock for Section 148 notices from the date of the deemed notice. Orders issued without proper jurisdiction, or those inconsistent with statutory prescriptions, are a nullity, and there can be no waiver of such fundamental jurisdictional requirements.

713

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2023 to 2026.

Also referred to as

Union of India v. Rajeev Bansal · Section 148 notice limitation · Ashish Agarwal legal fiction · TOLA applicability · reassessment jurisdiction · time-barred notice · order without jurisdiction · Section 149 · Section 148A

Also reported as

167 Taxmann.com 70301 Taxmann 238

Sections most often in play

Section 148Section 147Section 148ASection 151Section 149Section 144BSection 250Section 144
Read the full judgment

Issues it is cited on

section 149a(c)section 149a(d)section 149asection 151(i)section 149(1)(a)section 3(1)section 148a(a)section 148 noticesection 151(ii)section 149(1)section 149(1)(b)order under section 148a(d)

Judgments citing Union of India v. Rajeev Bansal

Deputy Commissioner of Income Tax, Central Circle-1(2), Kolkata vs. M/S Siddheshwari Vyapaar Private Limited, Kolkata

The appeal of the Revenue is dismissed

ITA 2550/KOL/2025[2014-15]Status: DisposedITAT Kolkata26 Feb 2026AY 2014-15

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: S/Shri Soumitra ChoudhuryFor Respondent: Shri S.B. Chakraborthy, DR
Section 143(3)Section 148Section 148ASection 149(1)(b)Section 153CSection 69C

…f the Act, was issued u/s 30.07.2022. We find that {Taxation and Other Laws [Relaxation and Amendment of Certain Provisions] Act} TOLA is not applicable. In the present case as has been admitted in the case of Union of India and other Vs. Rajeev Bansal [2024] 469 ITR 46 (SC), dated 03.10.2024. Therefore, the notice u/s 148 of the Act dated 30.07.2022, is barred by limitation and so is the assessment framed consequently u/s 143(3)/ 147 of the Act. We note that as per the Section 149(1) of the Act, the time limit for issue of notice u/s 148 of the Act for A.Y. 2014-15 before 01.04.2021, would be as per the old prov…

Jayantika Jatia, Kolkata vs. DCIT, Circle 29, Kolkata

In the result, the appeal of the assessee is allowed

ITA 2250/KOL/2025[2016-2017]Status: DisposedITAT Kolkata26 Feb 2026AY 2016-2017

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Jayantika Jatia Dcit, Circle 29, Shree Gunjan, 7, Ronaldshay Aaykar Bhawan Dakshin,2, Road, Kolkata-700027, West Gariahat Road(South), Kolkata- Vs. Bengal 700031, West Bengal (Appellant) (Respondent) Pan No. Akwpm8544K Assessee By : Shri Sunil Surana, Ar Revenue By : Shri Sandip Sarkar, Dr Date Of Hearing: 27.01.2026 Date Of Pronouncement: 26.02.2026

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Sandip Sarkar, DR
Section 144BSection 147Section 148Section 148ASection 151

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRIPRADIP KUMAR CHOUBEY, JM Jayantika Jatia DCIT, Circle 29, Shree Gunjan, 7, Ronaldshay Aaykar Bhawan Dakshin,2, Road, Kolkata-700027, West Gariahat Road(south), Kolkata- Vs. Bengal 700031, West Bengal (Appellant) (Respondent) PAN No. AKWPM8544K Assessee by : Shri Sunil Surana, AR Revenue by : Shri Sandip Sarkar, DR Date of hearing: 27.01.2026 Date of pronouncement: 26.02.2026 O R D E R Per Rajesh Kumar, AM: This is an appeal preferred by the assessee against the order of the National Faceless Appeal Centre, Delhi (herei…

Sri Sukumar Kuity, East Midnapore vs. A.O., NFAC, Delhi

In the result, the appeal of the assessee is allowed

ITA 1805/KOL/2025[2015-2016]Status: DisposedITAT Kolkata26 Feb 2026AY 2015-2016

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm**

Section 143(2)Section 144BSection 147Section 148Section 44A

…he AY 2015-16. - 2. The only issue raised by the Counsel of the assessee is in respect of A.Y. 2015-16, being time barred by limitation in consonance with the decision of the Hon'ble Apex Court in the case of Union of India and other Vs. Rajeev Bansal [2024] 469 ITR 46 (SC), dated 03.10.2024. - 3. The facts in brief are that the case of the assessee was reopened upon credible information regarding cash deposited in bank account maintained with SBI of ₹10,08,000/- and Union bank of India of ₹46,35,100/- for A.Y. 2014-15 but not filed any return of income, as received through the Insight Portal. Upon considering…

Bajranglal Bhawarlal Sharma, Borivali East vs. Income Tax Officer, Kautilya Bhavan

ITA 285/MUM/2026[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rajesh SalujaFor Respondent: Shri Aditya Rai
Section 143(3)Section 144BSection 147Section 148Section 148ASection 50CSection 50C(2)

…me) for the Assessment Year 2017-2018 after the expiry of three years from the end of the relevant assessment year. 6. In this regard we deem it appropriate to refer to judgment of the Hon’ble Supreme Court in the case Union of India vs. Rajeev Bansal [2024] 469 ITR 46 (SC)[03/10/2024]. The Hon’ble Supreme Court had, while dealing with the issue of approval from specified authority in terms of Section 151 of the Act, made the following observations: “74. The above table indicates that the specified authority is directly co-related to the time when the notice is issued. This plays out as follows under the old reg…

Sapna Umesh Dutta, Mumbai vs. ITO Ward, 41(2)(5), Mumbai

ITA 263/MUM/2026[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: passing Order, under Section 148A(d) of the Act and issuing notice dated 31/07/2022, the Assessing Officer obtained approval/sanction from the Principal Commissioner of Income Tax, Mumbai. The reassessment proceedings culminated into passing of the Assessment Order, dated 23/05/2023, under Section 147 of the Act. The appeal preferred by the Assessee against the aforesaid Assessment Order was dismissed by the CIT(A) vide Order, dated 27/11/2025. Being aggrieved, the Assessee has preferred th

For Appellant: Shri Tanmay PhadkeFor Respondent: Shri Aditya Rai
Section 147Section 148Section 148ASection 151Section 151A

…me) for the Assessment Year 2017-2018 after the expiry of three years from the end of the relevant assessment year. 6. In this regard we deem it appropriate to refer to judgment of the Hon’ble Supreme Court in the case Union of India vs. Rajeev Bansal [2024] 469 ITR 46 (SC)[03/10/2024]. The Hon’ble Supreme Court had, while dealing with the issue of approval from specified authority in terms of Section 151 of the Act, made the following observations: “74. The above table indicates that the specified authority is directly co-related to the time when the notice is issued. This plays out as follows under the old reg…

ITO 13(2)(1), Mumbai vs. Ska Sales Private Limited, Mumbai

ITA 5967/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

For Appellant: Shri Prakash Jhunjhunwala &For Respondent: Shri Nakul Agrawal
Section 143(3)Section 144BSection 147Section 148Section 148ASection 68Section 69Section 69C

…oceedings which goes to the root of the matter. In order to adjudicate upon the contentions raised by both the sides we deem it appropriate to refer to the following observations of the Hon’ble Supreme Court in the case Union of India vs. Rajeev Bansal [2024] 469 ITR 46 (SC)[03/10/2024]” “iii. Finance Act 2021 10. The Finance Act 2021 substituted the entire scheme of reassessment under sections 147 to 151 of the Income-tax Act with effect from 1 April 2021. Substantial changes were brought about by the new regime. Broadly speaking, they are summarized thus: (i) Section 148 mandates the assessing officer to initi…

Ska Sales Pvt Ltd, Mumbai vs. Income Tax Officsr, Ward 13(2)(1), Mumbai

ITA 5527/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18
Section 143(3)Section 144BSection 147Section 148Section 148ASection 68Section 69Section 69C

…oceedings which goes to the root of the matter. In order to adjudicate upon the contentions raised by both the sides we deem it appropriate to refer to the following observations of the Hon'ble Supreme Court in the case Union of India vs. Rajeev Bansal [2024] 469 ITR 46 (SC)[03/10/2024]” "iii. Finance Act 2021 10. The Finance Act 2021 substituted the entire scheme of reassessment under sections 147 to 151 of the Income-tax Act with effect from 1 April 2021. Substantial changes were brought about by the new regime. Broadly speaking, they are summarized thus: (i) Section 148 mandates the assessing officer to initia…

Dy. Commissioner of Income-Tax-1(1)(1), Mumbai vs. M/S. Hindustan Petroleum Corporation Limited, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 3866/MUM/2025[2015-16]Status: DisposedITAT Mumbai26 Feb 2026AY 2015-16

Bench: Shri Amit Shukla & Shri Girish Agrawaldy. Commissioner Of Income- Vs Hindustan Petroleum Tax-1(1)(1), Corporation Limited Mumbai Petroleum House Jamshedji Tata Road, Marine Lines S.O Mumbai - 400020 (Pan: Aaach1118B) Appellant Respondent Present For: Assessee By : Ms. Hirali Desai, Ca Revenue By : Shri Ritesh Misra, Cit Dr Date Of Hearing : 23.02.2026 Date Of Pronouncement : 26.02.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Revenue Is Against The Order Of National Faceless Appeal Centre (Nfac), Delhi Vide Order No. Itba/Nfac/S/250/2024-25/1075143492(1) Dated 27.03.2025 Passed Against The Assessment Order By The Assessment Unit, U/S. 147 R.W.S. 144 Read With Sec. 144B Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 25.05.2023 For Ay 2015-16. 2. Grounds Taken By The Revenue Are Reproduced As Under: “. Whether On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Erred In Deleting The Addition Of Rs. 9,60,00,000/ - On Account Of Disallowance Of Investment Allowance Claimed U/S. 32Ac On Dispensing Units In Retail Outlets Ignoring The Fact That The Dispensing Units Do Not Fall Within The Meaning Of Plant & Hence, Not Eligible For Claim Of Deduction U/S. 32Ac.

For Appellant: Ms. Hirali Desai, CAFor Respondent: Shri Ritesh Misra, CIT DR
Section 115JSection 144BSection 147Section 148Section 151ASection 32A

…IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER Dy. Commissioner of Income- vs Hindustan Petroleum Tax-1(1)(1), Corporation Limited Mumbai Petroleum House Jamshedji Tata Road, Marine Lines S.O Mumbai - 400020 (PAN: AAACH1118B) Appellant Respondent Present for: Assessee by : Ms. Hirali Desai, CA Revenue by : Shri Ritesh Misra, CIT DR Date of Hearing : 23.02.2026 Date of Pronouncement : 26.02.2026 O R D E R PER GIRISH AGRAWAL, ACCOUNTANT MEMBER: This appeal filed by the Revenue is against the order of National Faceless Appeal…

ACIT Central Circle 1(3), Ahmedabad vs. Unicorn Packaging LLP, Ahmedabad

In the result, this appeal of the Revenue is, accordingly, stands dismissed

ITA 898/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2020-21

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 32(1)Section 43(1)Section 43(6)(c)Section 49(1)(iii)Section 55(2)(a)

…ssesses with the relevant material and information relied upon by the Revenue within thirty days from the date of the judgment. The effect of this direction was summarized by the Apex Court in the case of Rajeev Bansal [2024] 167 taxmann.com 70/301 Taxman 238/469 ITR 46 (SC) as under: ITA Nos.893, 894, 896 to 898/Ahd/2025 ACIT vs. Unicorn Packaging LLP & Asst. Years : 2016-17, 2017-18. 2018-19 & 2020-21 106. …..To summarize, the combined effect of the legal fiction and the directions issued by this Court in Ashish Agarwal (supra) is that the show cause notices that were deemed to have been issued during the per…

ACIT Central Circle 1(3), Ahmedabad vs. Unicorn Packaging LLP, Ahmedabad

In the result, this appeal of the Revenue is, accordingly, stands dismissed

ITA 897/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2018-19

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 32(1)Section 43(1)Section 43(6)(c)Section 49(1)(iii)Section 55(2)(a)

…ssesses with the relevant material and information relied upon by the Revenue within thirty days from the date of the judgment. The effect of this direction was summarized by the Apex Court in the case of Rajeev Bansal [2024] 167 taxmann.com 70/301 Taxman 238/469 ITR 46 (SC) as under: ITA Nos.893, 894, 896 to 898/Ahd/2025 ACIT vs. Unicorn Packaging LLP & Asst. Years : 2016-17, 2017-18. 2018-19 & 2020-21 106. …..To summarize, the combined effect of the legal fiction and the directions issued by this Court in Ashish Agarwal (supra) is that the show cause notices that were deemed to have been issued during the per…

ACIT CC-1(3), Ahmedabad vs. Unicorn Packaging LLP, Ahmedabad

In the result, this appeal of the Revenue is, accordingly, stands dismissed

ITA 896/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 32(1)Section 43(1)Section 43(6)(c)Section 49(1)(iii)Section 55(2)(a)

…ssesses with the relevant material and information relied upon by the Revenue within thirty days from the date of the judgment. The effect of this direction was summarized by the Apex Court in the case of Rajeev Bansal [2024] 167 taxmann.com 70/301 Taxman 238/469 ITR 46 (SC) as under: ITA Nos.893, 894, 896 to 898/Ahd/2025 ACIT vs. Unicorn Packaging LLP & Asst. Years : 2016-17, 2017-18. 2018-19 & 2020-21 106. …..To summarize, the combined effect of the legal fiction and the directions issued by this Court in Ashish Agarwal (supra) is that the show cause notices that were deemed to have been issued during the per…

ACIT Central Circle 1(3), Ahmedabad vs. Unicorn Packaging Private Limited, Ahmedabad

In the result, this appeal of the Revenue is, accordingly, stands dismissed

ITA 895/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 32(1)Section 43(1)Section 43(6)(c)Section 49(1)(iii)Section 55(2)(a)

…ssesses with the relevant material and information relied upon by the Revenue within thirty days from the date of the judgment. The effect of this direction was summarized by the Apex Court in the case of Rajeev Bansal [2024] 167 taxmann.com 70/301 Taxman 238/469 ITR 46 (SC) as under: ITA Nos.893, 894, 896 to 898/Ahd/2025 ACIT vs. Unicorn Packaging LLP & Asst. Years : 2016-17, 2017-18. 2018-19 & 2020-21 106. …..To summarize, the combined effect of the legal fiction and the directions issued by this Court in Ashish Agarwal (supra) is that the show cause notices that were deemed to have been issued during the per…

ACIT Central Circle 1(3), Ahmedabad vs. Unicorn Packaging LLP, Ahmedabad

In the result, this appeal of the Revenue is, accordingly, stands dismissed

ITA 894/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 32(1)Section 43(1)Section 43(6)(c)Section 49(1)(iii)Section 55(2)(a)

…ssesses with the relevant material and information relied upon by the Revenue within thirty days from the date of the judgment. The effect of this direction was summarized by the Apex Court in the case of Rajeev Bansal [2024] 167 taxmann.com 70/301 Taxman 238/469 ITR 46 (SC) as under: ITA Nos.893, 894, 896 to 898/Ahd/2025 ACIT vs. Unicorn Packaging LLP & Asst. Years : 2016-17, 2017-18. 2018-19 & 2020-21 106. …..To summarize, the combined effect of the legal fiction and the directions issued by this Court in Ashish Agarwal (supra) is that the show cause notices that were deemed to have been issued during the per…

ACIT Central Circle 1(3), Ahmedabad vs. Unicorn Packaging LLP, Ahmedabad

In the result, this appeal of the Revenue is, accordingly, stands dismissed

ITA 893/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 32(1)Section 43(1)Section 43(6)(c)Section 49(1)(iii)Section 55(2)(a)

…ssesses with the relevant material and information relied upon by the Revenue within thirty days from the date of the judgment. The effect of this direction was summarized by the Apex Court in the case of Rajeev Bansal [2024] 167 taxmann.com 70/301 Taxman 238/469 ITR 46 (SC) as under: ITA Nos.893, 894, 896 to 898/Ahd/2025 ACIT vs. Unicorn Packaging LLP & Asst. Years : 2016-17, 2017-18. 2018-19 & 2020-21 106. …..To summarize, the combined effect of the legal fiction and the directions issued by this Court in Ashish Agarwal (supra) is that the show cause notices that were deemed to have been issued during the per…

Msn Laboratories Private Limited, Hyderabad vs. Addl. CIT, Central Range-2, Hyderabad

In the result, the appeals filed by the assessee for the A

ITA 2172/HYD/2025[2021-22]Status: DisposedITAT Hyderabad25 Feb 2026AY 2021-22

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos. 2164, 2165, 2171 & 2172/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2018-19 To 2021-22) M/S. Msn Laboratories (P) Ltd Vs. Additional Cit Hyderabad Central Range-2 Pan:Aadcm6283F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 21/01/2026 घोषणा की तारीख/Pronouncement: 25/02/2026 आदेश/Order Per. Manjunatha, G. A.M. These Four Appeals Filed By The Assessee Are Directed Against The Separate, But Identical Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad, All Dated 08/10/2025 For The A.Ys 2018-19 To 2021-22 Respectively. Since, Identical Issues Have Been Raised By The Assessee In All These Four Appeals, For The Sake Of Convenience, These Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 153ASection 269Section 271DSection 274

…ITA Nos 2164 2165 2171 and 2172 MSN Laboratories P Ltd आयकर अपील"य अ"धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ B ‘ Bench, Hyderabad "ी "वजय पाल राव, उपा" य" एवं "ी मंजुनाथ जी, लेखा सद" य के सम" । Before Shri Vijay Pal Rao, Vice-President A N D Shri Manjunatha G. Accountant Member आ.अपी.सं /ITA Nos. 2164, 2165, 2171 & 2172/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2018-19 to 2021-22) M/s. MSN Laboratories (P) Ltd Vs. Additional CIT HYDERABAD Central Range-2 PAN:AADCM6283F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee by: Shri M.V. Prasad, CA राज" व "ारा/Revenue by: Dr. Sa…

Msn Laboratories Private Limited, Hyderabad vs. Addl CIT, Central Range-2, Hyderabad

In the result, the appeals filed by the assessee for the A

ITA 2165/HYD/2025[2019-20]Status: DisposedITAT Hyderabad25 Feb 2026AY 2019-20

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos. 2164, 2165, 2171 & 2172/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2018-19 To 2021-22) M/S. Msn Laboratories (P) Ltd Vs. Additional Cit Hyderabad Central Range-2 Pan:Aadcm6283F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 21/01/2026 घोषणा की तारीख/Pronouncement: 25/02/2026 आदेश/Order Per. Manjunatha, G. A.M. These Four Appeals Filed By The Assessee Are Directed Against The Separate, But Identical Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad, All Dated 08/10/2025 For The A.Ys 2018-19 To 2021-22 Respectively. Since, Identical Issues Have Been Raised By The Assessee In All These Four Appeals, For The Sake Of Convenience, These Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 153ASection 269Section 271DSection 274

…ITA Nos 2164 2165 2171 and 2172 MSN Laboratories P Ltd आयकर अपील"य अ"धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ B ‘ Bench, Hyderabad "ी "वजय पाल राव, उपा" य" एवं "ी मंजुनाथ जी, लेखा सद" य के सम" । Before Shri Vijay Pal Rao, Vice-President A N D Shri Manjunatha G. Accountant Member आ.अपी.सं /ITA Nos. 2164, 2165, 2171 & 2172/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2018-19 to 2021-22) M/s. MSN Laboratories (P) Ltd Vs. Additional CIT HYDERABAD Central Range-2 PAN:AADCM6283F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee by: Shri M.V. Prasad, CA राज" व "ारा/Revenue by: Dr. Sa…

Ramesh Amratlal Brahmbhatt, Mumbai vs. ITO Ward 34(3)(2), Mumbai

In the result, the reassessment order dated 20

ITA 9067/MUM/2025[2014-15]Status: DisposedITAT Mumbai25 Feb 2026AY 2014-15

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarramesh Amratlal Ito Ward 34(3)(2), Brahmbhatt Kautilya Bhavan, 43 Rajnigandha, Vs. Bandra Kurla Gulmohar Cross Road No. Complex, Mumbai – 11, J V P D Scheme, 400 051 Juhu, Mumbai-400 049 Pan/Gir No. Aabpb7235R (Applicant) (Respondent) Assessee By Shri K. Gopal & Ms. Neha Paranjpe, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 23.02.2026 Date Of Pronouncement 25.02.2026

Section 10(38)Section 144BSection 147Section 148Section 149Section 151ASection 68

…ithout jurisdiction and bad in law. 2. The notice dated 27.07.2022 under section 148 of the Act issued for the Assessment Year: 2014-15 is barred by limitation in view of the observations of the Hon’ble Supreme Court in the case of UOI v. Rajeev Bansal [2024] 469 ITR 46 (SC) [03-10-2024]. Thus, the said notice issued under section 148 of the Act is bad in law and void ab initio. 3. The notice dated 27.07.2022 issued by the Jurisdictional Assessing Officer under section 148 of the Act is in contravention of the provisions of section 151A of the Act. Hence, the same is illegal and bad in law. 4. The notice dated 29…

DCIT-19(1), Mumbai vs. Nimesh Pravinchandra Mehta, Mumbai

The appeal is allowed

ITA 8102/MUM/2025[2013-14]Status: DisposedITAT Mumbai25 Feb 2026AY 2013-14

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

Section 143(3)Section 148Section 148ASection 69C

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “B” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND MS. KAVITHA RAJAGOPAL (JUDICIAL MEMBER) ITA No. 8102/MUM/2025 Assessment Year: 2013-14 DCIT-19(1), Piramal Chamber, Lal Baug, Mumbai-400012. Appellant Vs. Nimesh Pravinchandra Mehta, 10, 4th floor, Kalyan Bldg. No. 8, Khadilkar Road, Girgaun, Mumbai-400 004. PAN NO. AAOPM 7984 P Respondent Assessee by Revenue by Date of Hearing Date of pronouncement : Mr. Ketan Vajani, CA : Mr. Swapnil Choudhari, Sr. DR : 12/02/2026 : 25/02/2026 ORDER PER OM PRAKASH KANT, AM This appeal by the Revenue is directed agai…

DCIT Central Circle- 7(1), Mumbai vs. Jinalben Bhavikbhai Vora, Gujrat

ITA 7588/MUM/2025[2013-14]Status: DisposedITAT Mumbai24 Feb 2026AY 2013-14

Bench: the expiry of 6 years from the end of Assessment Year 2013-2014). Subsequently, in compliance with the judgment of the Hon'ble Supreme Court in the case of Union of India VS. Ashish Agarwal 444 ITR 1 (SC) [04/05/2022], communication, dated 26/05/2022, was sent to the Assessee intimating that the aforesaid notice issued under Section 148 of the Act (under old regime) would be treated as the show-cause notice issued in terms of Section 148A(b) of the Act (under new regime introduced by the Fi

For Appellant: Shri Jignesh ShahFor Respondent: Shri Nakul Agrawal
Section 147Section 148Section 148ASection 151A

…Section 148A(d) of the Act and has issued notice under Section 148 of the Act (new regime) after the expiry of surviving period as computed according the judgment of the judgment of the Hon’ble Supreme Court in the case Union of India vs. Rajeev Bansal [2024] 469 ITR 46 (SC)[03/10/2024]. Therefore, both, the order under Section 148A(d) of the Act and the notice under Section 148 of the Act (new regime) are barred by limitation. In this regard the Learned Authorized Representative for the Assessee furnished following details: Sr. No. Event/Action Date/Period 1 Issuance of notice u/s 148 of the Act under old regim…

Beena Kandarpkumar Parikh, Ahmedabad vs. The Dy.CIT, Circle-3(1)(1), Ahmedabad

In the result, the appeal of the asessee is allowed in above terms

ITA 393/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad23 Feb 2026AY 2015-16

Bench: SHRI SANJAY GARG (Judicial Member), SMT. ANNAPURNA GUPTA (Accountant Member)

For Appellant: Shri Tushar Hemani, Sr. AdvocateFor Respondent: Shri Rohit Aasudani, Sr. DR
Section 250Section 69

…upra), the notice u/s.148 of the Act in this case was issued on 31.08.2022. Ld. Counsel for the assessee pointed out that in the case of Hindva Builders (supra), the ITAT noted that Hon’ble Supreme Court in the case of Union of India vs. Rajeev Bansal, [2024] 469 ITR 46 ITA No.393/Ahd/2025 [Beena Kandarpkumar Parikh vs. DCIT] A.Y. 2015-16 - 4 – (SC) had noted that the Revenue had conceded before the Hon’ble Apex Court to the effect that so far as the A.Y. 2015-16 is concerned, the Revenue could not have issued the notices u/s.3(1) of TOLA considering the time period as prescribed u/s.149 of the Act w.e.f. 01.04.…